Capital Gains Manual

Bare trusts: absolutely entitled judicial comment

Comments on the meaning of the expression `absolutely entitled as against the trustee’ may be found in these tax cases. The first three of them were in fact concerned with the question whether the beneficiary had become absolutely entitled. In such a case there is a deemed disposal by the trustees when absolute entitlement occurs. See CG37000 - CG37001 and TCGA92/S71 (1).